Every skilled or long-term care facility must always consider the possibility that it will have to be evacuated in case of a dire emergency. An evacuation procedure is not just “nice-to-have”—it is, in fact, one of the dictates of the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule which all facilities must have in place by November 15, 2017 to be compliant with federal regulations.
The first—and possibly the most important—aspect of an evacuation plan must be the identification of reception facilities. These should be identified—and arrangements made prior to any emergency—by geographic distance from the dispatching facility.
These receiving facilities can, for example, be graduated by distance in terms of the extent of the emergency. An “active shooter” emergency might require a nearby receiving facility, while a fire, flood, or hurricane will obviously require a far more distant reception center.
Identifying the reception centers is only the beginning: a written evacuation procedure must also show how the facility will track staff and residents during an evacuation, how and when the determination will be made to evacuate, and how information will be sent to the evacuation destination—usually another SNF facility—while adhering to HIPAA privacy/confidentiality requirements. In this regard, patient records should be secure and readily available during an emergency.
Included in evacuation planning should be the methods of transportation likely to be used—given the reality that normal vehicles may be unusable, or that roads may be flooded or otherwise rendered unsafe.
Alternative means of communication should also be prepared in the eventuality that ordinary telephones are no longer operational.
At the same time, the evacuation procedure must provide details of how the patients will continue to receive care and treatment, and how the staff responsibilities will be apportioned.
In addition, evacuation protocols should be in place not only for patients, but also for staff members and families/patient representatives.
Furthermore, the federally-mandated Final Rule on emergency preparedness dictates that a facility must have policies and procedures to address a means to shelter in place for patients, staff, and volunteers who remain in the facility.
The evacuation procedure must take into account the possibility that the facility itself may be used as an evacuation destination. As such, prior arrangements with other facilities in the area should be in place to serve as alternate care sites.
In this regard, all facilities should be aware that the authorities can declare any institution providing medical care for inpatients as a designated site for the “provision of care and treatment . . . [as] identified by emergency management officials.”
All evacuation policies should as a matter of course contain full contact and collaboration details with local emergency officials.
An emergency which causes an evacuation can significantly affect an institution’s functioning—hence the legal requirement to plan for all possible scenarios.
